Have You Done Yours?
By Michael R. Christians
Pursuant to the Dodd-Frank Act, rules amending the loan originator qualification requirements found in Section 1026.36(f)(3)(iii) of Regulation Z were issued by the Consumer Financial Protection Bureau in January 2014. Those rules dictate loan originators receive periodic training covering federal and state law requirements that apply to their individual loan origination activities. Here’s a bit of a breakdown to help your leadership comply with the new training regulations.
Staff members who meet the definition of loan originator under Regulation Z must receive periodic training. Keep in mind, however, the definition is quite broad. It includes not only loan officers, but others who take applications, offer or arrange for the extension of credit or otherwise represent to the public that they can perform any of these tasks.
The breadth of the definition means your credit union may have loan support staff, call center representatives and even new accounts personnel who fall within the definition of loan originator. Therefore, it’s important to be sure you are including all necessary staff in your periodic training program.